Last modified: October 5, 2021
Our Commitment to Your Privacy
Personal Information We Collect and Process
We collect and process certain information from you directly, such as information you enter yourself and data about your participation in courses.
When using our Services, you may provide contact information, such as your name, address, telephone number, email address, and date of birth.
In order to use certain features of the Site (e.g., enrolling in a course), you need to create a user account (“Account”). When you create or update your Account, we collect and store the data you provide, such as your email address, password, date of birth, and account settings and assign you a unique identifying number (“Account Data”).
You can also choose to provide profile information such as a photo, biography, language, country, or other data (“Profile Data”). Your Profile Data will be publicly viewable by others.
Parts of the Services let you interact with other users or share content publicly, including by posting reviews on a course page, or submitting comments, questions, or feedback on the Site or otherwise in connection with the Services. Such shared content may be publicly viewable by others depending on where it is posted on the Site.
Course Activity Data
When you enroll in and take courses, we collect certain data including which courses you have started and completed; course purchases; course certificates; your exchanges with instructors and/or other users of the courses; and materials submitted to satisfy course requirements.
If you make purchases, we collect certain data about your purchase (such as your name and zip code/address) as necessary to process your order. All payment and billing data, including your name, credit card information, billing address, and zip code, is provided directly to our payment processing partners. For security purposes, we do not collect or store such payment processing data.
Surveys and Offers
Communications and Support
If you contact us for support or to report a problem or concern (regardless of whether you have created an Account), we collect and store your contact information, messages, and other data in connection with such communication.
We also collect certain information by automatic means, such as data about your device and browser characteristics.
Technical data about your computer or device, such as your IP address, device type, unique device identifiers, browser, domain and other systems data, and platform types (“System Data”).
Usage data about your interactions with the Site, including courses accessed, time spent on the Site, pages visited, features used, your search queries, click data, date and time, and other data regarding your use of the Site and Services (“Usage Data”).
Approximate geolocation data (such as country) based on your IP address.
How We Collect the Personal Information
We may obtain Personal Information:
- When you provide it directly to us through both online and offline interactions, such as via Site submissions or when you email us;
- Automatically when you visit this Site or use the Services (such as from cookies, as further described below);
- From our affiliates and partners including Thinkific, which provides Wine Institute with the underlying software platform we use to build and deliver our online educational courses, and Brillium Inc., which provides testing software integrated with Thinkific’s platform.
If you submit any Personal Information relating to other people to us, you represent that you have the authority to do so.
Cookies and other similar technologies
We use the following specific Cookies on our Site:
· Google Analytics
· Screen options cookies
Strictly Necessary Cookies
These cookies are essential in order to enable you to move around the Website and use its functionalities.
These cookies remember choices you make such as the country you visit our Site from, language and search parameters. This data can then be used to provide you with an experience more appropriate to your selections and to make the visits more tailored and pleasant. The information these cookies collect may be anonymized or pseudonymized and they cannot track your browsing activity on other sites.
These cookies collect anonymous or pseudonymous information on how people use our Site.
Your web browser can be set to allow you to control whether you will accept cookies, reject cookies, or to notify you each time a cookie is sent to you. Please note that if your browser is set to reject cookies, the Site may not recognize you when you return to the Site and some website functionality may be lost. The Help section of your browser may tell you how to prevent your browser from accepting cookies. To find out more about cookies and your choices with respect to collection and use of such data, you may visit www.allaboutcookies.org, or the Digital Advertising Alliance’s (DAA) opt-out page at http://www.aboutads.info/choices, or the National Advertising Initiative’s (NAI) opt-out page at http://www.networkadvertising.org/choices/.
Do Not Track
Do Not Track (“DNT”) is a privacy preference that users can set in their web browsers. When a user turns on DNT, the browser sends a message to websites requesting that they do not track the user. At this time, the Wine Institute does not track your or any other users’ Personal Information over time and across third party websites. We therefore do not respond to browser DNT signals, but this does not affect your privacy choices. For information about DNT, visit www.allaboutdnt.org.
How We Use the Personal Information and the Legal Grounds for Such Use
We may process the Personal Information that we collect in furtherance of our legitimate interests in providing you with the Services, to fulfill the terms of a contract you have with us (such as providing you with access to a course you are taking), with your consent, or in order to comply with our legal obligations. In some cases, failure to provide such Personal Information will mean that we cannot provide you with the Services.
Specifically, we process the Personal Information we collect for one or more of the following business and legal purposes:
- operate our business (including to provide, personalize, and improve or otherwise develop this Site and our products and services);
- provide and administer the Services, including to facilitate course enrolment, participation and certificates;
- process your requests and orders for courses, products, specific services, information, or features;
- respond to an inquiry and any related activity that may result from your inquiry;
- market and administer surveys, promotional offers, and programs administered or sponsored by the Wine Institute or our partners;
- ensure the security and integrity of this Site and its content;
- manage our vendor and partner relationships;
- enforce our Terms of Service and other legal terms and policies;
- protect our and others’ interests, rights, and property (such as to protect our copyrighted materials); and
- ensure compliance with local legal and regulatory requirements.
How We Share the Personal Information
We share Personal Information with third parties in the following ways:
- With instructors and other users of the Site, in connection with and as necessary for the facilitation of courses and other Services provided to you.
- To authorized third-party service providers or others who may perform services on our behalf, such as payment processing, data analysis, marketing and advertising services, and customer service and support. These service providers may access and use your Personal Information to provide our requested service(s). In addition, we have entered into data processing agreements with these service providers, if required by applicable law.
- If we believe disclosure is appropriate to prevent physical, financial, or other harm, injury, or loss.
- To legal, governmental, or judicial authorities, if we believe it is appropriate, as instructed or required by those authorities or applicable laws, or in relation to a legal activity, such as in response to a subpoena or investigating suspected illicit activity.
- As necessary to administer, market, or sponsor promotions and surveys you choose to participate in, as required by applicable law or in accordance with the rules of the promotion or survey.
- To the extent we decide to use an advertising-supported revenue model in the future, we may use and share certain System Data and Usage Data with third-party advertisers and networks to show general demographic and preference information among our users (such data will not include information identifying you, without your consent).
- We may disclose or use anonymized, aggregated or otherwise de-identified data for any purpose.
- As necessary to pursue a legitimate business or legal need to share your information, such as meeting our contractual obligations or as part of our business relationship (and in accordance with applicable law).
We use the following service providers:
· Thinkific – Thinkific is a publicly listed company located at 369 Terminal Avenue, Suite 400, Vancouver, BC V6A 4C4 Canada. Thinkific provides Wine Institute with the underlying software platform we use to build and deliver our online educational courses.
· Mailchimp – Mailchimp is a marketing platform created by The Rocket Science Group, LLC which is located at 675 Ponce de Leon Avenue NE, Suite 500, Atlanta, GA 30308 that we use for email marketing.
· Mapbox, Inc. – Mapbox, Inc. is located at 740 15th Street NW, Suite 500, Washington DC 20005 and provides custom online maps we use for maps of various wine regions.
· Vimeo, Inc. – Vimeo, Inc. is located at 555 West 18th Street, New York, NY 10011 and provides a video platform we use for educational videos.
· YouTube, Inc. – YouTube, Inc. is located at 901 Cherry Avenue, San Bruno, CA 94066 and provides a video platform we use for educational videos.
· Google Analytics – Google is located at 1600 Amphitheater Parkway, Mountain View, CA 94043 and provides a web analytics service we use to study user experience in aggregate to help us better understand how to improve navigation and usability.
Links To Third-Party Websites
We seek to use reasonable and appropriate physical, technical and administrative measures to protect the Personal Information that we collect and store. Unfortunately, no data transmission or storage system can be guaranteed 100% secure; therefore, we do not guarantee that your Personal Information will be secure from theft, loss, or unauthorized access or use, and we make no representation as to the reasonableness, efficacy, or appropriateness of the measures we use to safeguard such Personal Information. If you have reason to believe that your interaction with us is no longer secure, please notify us immediately.
The safety and security of your information also depends on you. Your password is an important part of our security system, and it is your responsibility to protect it. You should not share your password with any third party, and if you believe your password or Account has been compromised, you should change it immediately.
Depending on your jurisdiction, you may have certain rights regarding our collection, use, and sharing of your Personal Information. If you have any questions regarding these rights, please contact us at: firstname.lastname@example.org. Please note that we may request additional information to respond to or fulfill any requests regarding your rights under applicable laws or regulations.
You can always opt out of any subscription for emails, involving any updates, information, postings, and/or news, by clicking “Unsubscribe” at the bottom of the email. We might still send you certain important emails, like responding to you by email if you send us a request or comment.
If you are a resident of Nevada, California, the European Union, Switzerland, or United Kingdom, you have additional rights. See the applicable “Your Rights” sections below.
The Site is not intended for children, and our Service is only intended for adults. No one under the age of 18 may provide any Personal Information to the Site and we do not intend to collect Personal Information from children. Parents or adults can use various readily available software programs or other methods to prevent children or minors from accessing the Site. If you believe we might have any information from or about an individual who is under the age limit or for an unintended applicant on our Site, such as a child, please contact us.
The Wine Institute is headquartered in the United States, and by engaging with us you consent that we can host your Personal Information in the United States. We have operations, entities, and service providers in the United States and throughout the world. We and our service providers may transfer your Personal Information to, or access it in, jurisdictions that may not provide levels of data protection equivalent to your home jurisdiction. We will take steps to ensure that your Personal Information receives an adequate level of protection in the jurisdictions in which we process it. If you are located in the European Economic Area, United Kingdom, or Switzerland, we ensure an adequate level of protection is afforded where we transfer your Personal Information out of the EU/EEA by ensuring, where required by law, at least one of the following safeguards is implemented:
- Transferring Personal Information to countries that have been deemed to provide an adequate level of protection for Personal Information by the EU Commission, or
- Using specific contracts approved by the EU Commission which give Personal Information the same protection it has in Europe.
You may be entitled, in accordance with applicable law, to request a copy of the specific safeguard by contacting us as described below.
Data Subjects In The European Union (EU), the European Economic Area (EEA) and the United Kingdom (UK) – Legal Ground and Your Rights –
If you are located in the EU, EEA or the UK, the following applies additionally:
Legal Grounds for Processing
The processing of the above listed Personal Information is based on the following legal grounds:
· Contact Information / Account Data / Payment Data / Communication and Support / Shared Content / Course Activity Data: We process such personal data in order to comply with our contractual obligations with you, as follows:
- Provide and administer our Services;
- process your requests and orders for courses, products, specific services, information or features;
- respond to an inquiry and any related activity that may result from your inquiry; and
- post your reviews, comments, feedback and/ or questions on the Site.
· System Data / Usage Data: We process such personal data in order to protect the following legitimate interests:
· Surveys / Offers: We process such personal data in order to further our legitimate interests, as follows:
- improving our Site and products; and
- promoting our Services.
· Profile Data / Location Data: We will only process such personal data with your consent.
The sharing of Personal Information is based on the following legal grounds:
· With instructors / other user of the Site: in order to comply with our contractual obligations with you.
· As necessary to administer, market, or sponsor promotions and surveys: in order to comply with our contractual obligations with you.
· With legal, governmental, or judicial authorities: in order to comply with our legal obligations.
· As necessary to pursue a legitimate business or legal need / to prevent physical, financial, or other harm, injury or loss: in order to further our legitimate interests. Our interest is to provide our Services and prevent damages.
Data Subject Rights
Pursuant to the EU General Data Protection Regulation 2016/679 (GDPR) and where allowed by law, such as in the European Economic Area (EEA), United Kingdom, and Switzerland, and provided that the legal preconditions are fulfilled, if you are a resident of the EU, United Kingdom, or Switzerland, you have the right to:
- access your Personal Information;
- ask us to correct your Personal Information;
- ask us to delete your Personal Information;
- ask us to restrict processing of your Personal Information;
- obtain your Personal Information in a structured, machine readable format for data portability purposes;
- withdraw your consent at any time by emailing us at Legal@wineinstitute.org.
In addition, you can object to the processing of your Personal Information in some circumstances (including where we are using the data for direct marketing).
You further have the right to lodge a complaint with a data protection supervisory authority if you believe that our processing of your Personal Information does not comply with GDPR.
These foregoing data subject rights may be limited, for example, if fulfilling your request would reveal Personal Information about another person, or if you ask us to delete information which we are required by law to keep or have overriding legitimate interests in keeping. You can find more information here: https://ec.europa.eu/info/law/law-topic/data-protection/reform/rights-citizens_en
If you wish to contact us in relation to the exercise of any of your rights, please email us at: Legal@wineinstitute.org.
Your Rights – California Residents
Access to Specific Information and Personal Information Portability Rights
If you are a California resident, you have the right, subject to certain exceptions defined in the California Consumer Privacy Act (CCPA) and other applicable laws and regulations, to request that companies disclose certain information to you about their collection and use of your Personal Information over the past twelve (12) months. Please also note that we are not required to respond to your requests for access or disclosure of Personal Information more than twice in a twelve (12) month period.
This right of access includes information about:
· The categories of Personal Information we collected about you
· The categories of sources for the Personal Information we collected about you
· Our business or commercial purpose for collecting that Personal Information
· The categories of third parties with whom we share that Personal Information
· The categories of Personal Information that each recipient received
· The specific pieces of Personal Information we collected about you
You have the right, subject to certain exceptions defined in the CCPA and other applicable laws and regulations, to request that a company delete any of your Personal Information that it has collected from you and retained.
California consumers also have the right not to receive discriminatory treatment if they exercise the rights listed herein.
Request and Verification Process
When you make a request, we may require that you provide information and follow procedures so that we can verify the request and your jurisdiction before responding to it. The verification steps we take may differ depending on the request you make. We will match the information that you provide in your request to information we already have on file to verify your identity. If we are able to verify your request, we will process it. If we cannot verify your request, we may ask you for additional information to help us verify your request.
You will be required to submit your first and last name and email address and may be asked to provide your telephone number or address so that we can verify the request. Please provide as much of the requested information as possible to help us verify the request. We will only use the information received in a request for the purposes of responding to the request.
Sale or Sharing of Personal Information
You have the right, subject to certain exceptions defined in the CCPA and other applicable laws and regulations, to request that companies stop selling your personal information and refrain from doing so in the future. We are not currently selling your Personal Information.
California Civil Code Section 1798.83 permits California residents to request a list of all third parties to which we, during the immediately preceding calendar year, have disclosed certain Personal Information for direct marketing purposes. We do not share Personal Information with other people or non-affiliated businesses for their direct marketing purposes. We are only required to respond to a customer request once during any calendar year. To make such a request you should send a letter to the Wine Institute, 425 Market Street, Suite 1000, San Francisco, CA 94105. Please be aware that not all information sharing is covered by the California privacy rights requirements and only information sharing that is covered will be included in our response.
Your Rights – Nevada Residents
Although the Wine Institute does not sell Personal Information, Nevada residents have the right to submit a verified request directing us not to sell their Personal Information. If you are a Nevada resident, and would like to submit such a request, please send your request through any of the methods noted below at “Exercising Your Rights.”
Exercising Your Rights
To exercise your rights described above, please submit a request to us by either:
· Emailing us at Legal@wineinstitute.org ; or
- By mail at: 425 Market Street, Suite 1000, San Francisco, CA 94105.
How to Contact Us